ML18051B358

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Application for Amend to License DPR-20,clarifying Existing Tech Spec 3.15 by Reducing Unnecessary Reporting Requirements for Primary Coolant Sys Leakage
ML18051B358
Person / Time
Site: Palisades Entergy icon.png
Issue date: 04/30/1985
From: Dewitt R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18051B357 List:
References
NUDOCS 8505070131
Download: ML18051B358 (3)


Text

CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I.

Changes

1)

Change Technical Specification 3.l.5(a) to read as follows:

"a.

If the primary coolant system leakage exceeds 1 gpm and the source of the leakage is not identified, reduce unidentified primary coolant system leakage to less than 1 gpm within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or place the reactor in hot shutdown condition within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

2)

Change Technical Specification 3.1. 5 (b) to read as follows:

"b.

If leakage from the primary coolant system exceeds 10 gpm, reduce primary coolant system leakage to less than 10 gpm within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or place the reactor in hot shutdown condition within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown condition within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

3)

Delete Technical Specificat~on 3.l.5(e) in its entirety.

4)

Change Technical Specification 3.1.5 Basis to read as follows:

"Industry experience has shown that while a limited amount of leakage is expected from the primary coolant system, the unidentified portion of this leakage can be reduced to a threshold value of less than 1 gpm.

This threshold value is sufficiently low to ensure early detection of addttional leakage.

When the source of the leakage can be identified, the condition shall be evaluated to determine if operation can safety continue.

Justification for continued operation with identified leakage in excess of 1 gpm shall be documented in writing and approved by the Plant General Manager or his representative."

A maximum allowable primary coolant system leak rate of 10 gpm has been established.

This limitation does not include the primary coolant pump seal leak-off which is directed to the volume control tank.

The 10 gpm limitation provides allowances for a limited amount of leakage from known sources whose presence will not interfere with the detection of unidentified leakage.

A primary coolant system leak rate in excess of l_O gpm is indicative of a failure of sufficient magnitude to warrant shutdown for repair.

NU0485-018I('.*

8505070131 850430 l

PDR ADOCK 05000255 1

1

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The 10 gpm limitation is well within the 40 gpm capacity of one charging pump which would be available even under a loss of off-site power condition.

2 The initial 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period following indication of unidentified primary coolant system leakage in excess of 1 gpm, or total primary coolant system leakage in excess of 10 gpm, provides sufficient time to facilitate identification and confirmation of the leakage' source with the Plant being maintained in a stable condition.

When the source of the leakage cannot be identified or reduced, the following 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period is sufficient to bring the Plant to hot shutdown condition in an orderly manner.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period which follows provides adequate time to bring the Plant to cold shutdown condition in an orderly manner and to correct minor deficiencies.

If major repairs are necessary, a cold shutdown condition would be in order.

The limitations on secondary system specific activity ensure that the resultant off-site radiation dose will be limited to a small fraction of 10 CFR Part 100 limits in the event of a steam line rupture.

This dose also includes the effects of a coincident 1.0 gpm primary to secondary tube leak in the steam generator of the affected steam line and a concurrent loss of offsite electrical power."

II. Discussion The proposed change to Technical Specifications 3.1.S(a) and (b) is requested to provide a period for plant stabilization which will facilitate identification and confirmation of the leak source, rather than proceeding immediately toward hot shutdown condition.

The overall time period of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach hot shutdown condition following initial leak indication remains the same.

Technical Specification 3.1.S(e) is no longer applicable; consequently the specification is requested to be deleted.

The Basis section for Technical Specification 3.1.5 has been revised to reflect the above changes.

III. Analysis of No Significant Hazards Consideration We have received the proposed change to the Palisades Technical Specifications being made in accordance with the requirements of 10CFRS0.48 in order to determine whether or not this change involves a significant hazards consideration.

In our review, we have used the guidance of certain examples (48FR14870).

One of the examples (vi) in this guidance states that a change which either may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but when the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.

Since this proposed change does not change the time in which the plant must be in hot shutdown if primary coolant system leakage exceeds 1 gpm i.e. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, but rather the ramp down time from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, we have NU0485-0184C-NL04

IV.

determined that this change falls within the example and therefore the change does not involve a significant hazards consideration.

Conclusion 3

The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no significant hazards consideration.

This change has also been reviewed under the cognizance of the Nuclear Safety Board.

A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY B~l1&df-R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 30th day of April 1985.

fey, Notary County, Michigan My commission expires November 5, 1986.

SHERRY l YNN DURFEY Notary Public, Jackson County, MJeTt.

My Commission Expires Nov. 5, 1986 NU0485-0184C-NL04